This compares to a median gender pay gap of 9.3% and a mean gender pay gap of 13.4% for the reporting year 2017/18. The median gender pay gap for 2025/26 varies from 4.3% in Wales to 9.7% in London, and from 0.2% in hospitality to 20.6% in construction.
When looking at the job titles given by the person responsible for submitting a statement confirming the accuracy of their organisation’s pay gap figures, we find that there has been a rise in the proportion of submissions from those working in HR. In the reporting period 2017/18, 34% of all submissions were made by an HR professional, by 2025/26 this proportion had grown to 50%.
While firms who have HR people responsible for this reporting, rather than finance or senior leaders, are more likely to include a supporting narrative as to the drivers causing the gap and how they plan to tackle it, the proportion of all firms who include such a statement has fallen. From April 2027, all large employers will have to publish their plans to tackle their gender pay gaps.
What is a gender pay gap?
It is important to recognise the difference between requirements under equal pay legislation and those relating to gender pay gap reporting. The law gives a woman the right to the same pay as a man (and vice versa) when carrying out 'like' work, work that is rated as equivalent as defined by an analytical job evaluation study, or that is classed as being work of equal value. This is a right that the government is considering extending to ethnicity and disability.
However, gender pay gap reporting does not compare men and women doing the same work, equivalent work, or work of equal value, as would happen as part of an equal pay audit. Instead, this type of reporting compares the mean and median female pay with that of mean and median male pay at the same workplace.
Common bonus errors
While the gender pay gap requirement has been in place since 2017, employers can still make mistakes, such as when staff responsible for reporting move, new HR or payroll software is introduced, or when workplaces find themselves in scope for the first time because they have grown.
One common area of confusion is around reporting bonuses. For example, what counts as a bonus? Often, firms can assume this just applies to incentives, commission, performance, or profit share. However, bonuses cover much more, such as referral bonuses, payments in lieu of a pay rise (such as when someone is at the top of their pay scale), or cash or vouchers given to workers to reflect a jump in the cost-of-living. You can find more about what to include or exclude from government guidance.
Another common misinterpretation is around which group of employees to include in the calculation. When calculating the mean, median, and quartile gender pay gaps, you include all bonuses earned by full-pay relevant employees. However, when calculating the mean, median, and quartile gender bonus gaps, you include all the bonuses earned by relevant employees, not just your full-pay relevant employees. For example, someone who is paid less because they are on maternity, paternity, adoption, parental or shared parental leave, would be included as a relevant employee, but not as a full-pay relevant employee.
There is also a related issue of not including ‘so-called’ atypical workers. Not only are employers supposed to include those with a contract of employment, but they must also include those who are self-employed where they must perform the work themselves, such as casual workers or independent contractors.
Another misunderstanding is that instead of just including those who have earned a bonus in calculating the mean and median gender bonus gaps, all employees are included in your calculations. Or all those who were eligible for a bonus are included, even if they did not receive one. By contrast, when it comes to the bonus gap proportions, then all male relevant employees who earned a bonus are compared against all the relevant male employees, and the same for females.
The CIPD has recently updated its gender pay gap guidance.
To reflect some of these reporting errors that employers can make around gender bonus gap reporting, the CIPD has revised its gender pay gap guidance.
Consult our updated gender pay gap guidance here.
If you discover you have miscalculated your gender pay gap data, we recommend that you should flag this with the EHRC. While the amended data will mean that you will be flagged as responding late on the pay gap viewing service, you can present more accurate information, and will be able to explain this in your accompanying narrative.
Also, while the size of the bonus gap is important, so too are the proportions of men and women within an organisation who are eligible for a bonus, and the potential size of that bonus. So, it is important to reflect why this is in your narrative as well.
Consult our full guide to understanding gender pay gap reporting here.
